Information System, Chemicals Commerce

Two concerns arise which CSIN administration has not addressed so far. First, the emphasis has been to provide access only through well-established existing sources. No apparent effort has been made to consider the need for drawing together the multiplicity of information submitted to the EPA Office of Pesticides and Toxic Substances in an easily accessible form for agency use. With the exception of information contained in the Chemicals In Commerce Information System (CICIS), developed primarily to accommodate TSCA Inventory and other related information, regulatory personnel often are not aware what is already available and request repetitive submissions from industry. Furthermore, conclusions are drawn only from publicly available data-bases. Data already available within the agency are not readily accessible for its own personnel. Apparently, this situation is a result of non-responsiveness, so far, to TSCA Section 10 s mandate. 

The Chemicals in Commerce Information System (CICIS) is being designed to support regulatory decision making within the EPA Office of Toxic Substances. CICIS will contain data on substance identification, uses, production volume, disposal methods, health and safety studies, and exposure data. The TSCA inventory is part of CICIS. 

The Hazardous Materials Transportation Act, passed in 1975, is the primary law governing transportation of chemicals and hazardous materials. The act includes a comprehensive assessment of the regulations, information systems, container safety, and training for emergency response and enforcement. The regulations apply to any person who transports, or causes to be transported or shipped, a hazardous material or who manufactures, fabricates, marks, maintains, reconditions, repairs, or tests a package or container which is represented, marked, certified, or sold by such person for use in the transportation in commerce of certain hazardous materials. ... 

A former Assistant Administrator for Toxic Substances observed that such analyses are "based upon a fundamental lack of information and data. This in turn means that our information will be highly uncertain."(6) On the other hand, prior to the establishment of the PMN system, those chemicals for which EPA requested better data might otherwise have been produced or distributed in commerce with little or no testing whatever. 

The Council on Environmental Quafity, in consultation with the Administrator, the Secretary of Health and Human Services, the Secretary of Commerce, and the heads of other appropriate Federal departments or agencies, shall coordinate a study of the feasibility of establishing (1) a standard classification system for chemical substances and related substances, and (2) a standard means for storing and for obtaining rapid access to information respecting such substances. A report on such study shall be completed and submitted to Congress not later than 18 months after the effective date of enactment of this chapter. 

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